Corrective Action Plans

Finding 1226287 (2023-010)

Material Weakness 2023

NM

Reporting Internal Control / Segregation of Duties § 200.512

Recommendation We recommend that Management enhance its internal control structure, including financial close and reporting, to ensure timely filing of future federal Uniform Grant Guidance reporting packages. Management Response Corrective Action The District acknowledges the finding. The FY23 Sing...

Recommendation We recommend that Management enhance its internal control structure, including financial close and reporting, to ensure timely filing of future federal Uniform Grant Guidance reporting packages. Management Response Corrective Action The District acknowledges the finding. The FY23 Single Audit reporting package was not timely filed due to the delayed audit, prior-year close issues, turnover, and incomplete audit preparation. Corrective action includes implementing an audit calendar, preparing the SEFA timely and on the required basis, tracking audit requests, assigning responsibility for federal reporting items, and monitoring the Federal Audit Clearinghouse filing deadline. The District will submit future Single Audit reporting packages within the required timeframe. Due Date of Completion: In progress; procedures to be implemented for the FY26 audit cycle and ongoing thereafter. Responsible Party(ies) Superintendent, Director of Finance/Business Office, and contracted finance support.

View Audit 408952

Finding 1226240 (2023-009)

Material Weakness 2023

Mississippi County, Missouri

MO

Subrecipient Monitoring Reporting Cash Management

The Treasurer has reviewed the corrected SEFA and understands the errors. Funds will be reported accurately in the future.

View Audit 408896

Finding 1225996 (2023-001)

Material Weakness 2023

Universal Family Connection, Inc.

IL

Reporting

Corrective Action Management concurs with the auditor’s finding and will 1) hire personnel within the accounting and finance department so that all defined tasks can be performed in a more timely manner and 2) evaluate current processes to determine how to make them more efficient so that the curren...

Corrective Action Management concurs with the auditor’s finding and will 1) hire personnel within the accounting and finance department so that all defined tasks can be performed in a more timely manner and 2) evaluate current processes to determine how to make them more efficient so that the current personnel within the accounting and finance department are able to complete their tasks in a more timely manner. Persons Responsible: Marlin Bryant, CFO Date of Implementation: September 2024

View Audit 408663

Finding 1225855 (2023-002)

Material Weakness 2023

City of Dover

DE

Reporting

Staff review of Finance internal policy numbers F317 and F317A last updated November 7, 2014 and May 15, 2015 for changes pertaining to current year requirements. Additionally, training has been sought through GFOA for updated grant training for new staff. FSRS and SAM.gov training was completed in ...

Staff review of Finance internal policy numbers F317 and F317A last updated November 7, 2014 and May 15, 2015 for changes pertaining to current year requirements. Additionally, training has been sought through GFOA for updated grant training for new staff. FSRS and SAM.gov training was completed in December 2024. Lastly, an opening for Accountant II is being reconsidered for an Accountant III role to be used specifically for project and grant accounting purposes.

View Audit 408549

Finding 1224898 (2023-001)

Material Weakness 2023

Clearfield County

PA

Reporting

Finding 2023 -01 Pennsylvania Department of Human Services – Child Support Enforcement – Pennsylvania Automated Child Support Enforcement System (PACSES) Data Reliability Validation Criteria: Per the PACSES Office of Child Support Enforcement (OCSE) 157 Data Reliability Validation:  Line 5 should b...

Finding 2023 -01 Pennsylvania Department of Human Services – Child Support Enforcement – Pennsylvania Automated Child Support Enforcement System (PACSES) Data Reliability Validation Criteria: Per the PACSES Office of Child Support Enforcement (OCSE) 157 Data Reliability Validation:  Line 5 should be reporting children in IV-D cases open at the end of the current federal fiscal year who were born out-of-wedlock;  Line 6 should be reporting children in IV-D cases open during or at the end of the fiscal year with paternity established or acknowledged;  Line 24 should be reporting the total amount of current support due for the fiscal year; and  Line 25 should be reporting the total amount of support distributed and disbursed as current support during the fiscal year. Condition: During the audit, it was determined that several of the PACSES cases sampled from the Line-Item Reports did not match the PACSES case data in the County’s system. Cause: The County is inaccurately inputting case information into PACSES causes cases to be improperly included to be reflected on the Line-Item Reports generated from PACSES. Effect: The County is not in compliance with OCSE-157 requirements. This is causing inaccurate information to be presented on its reports to OCSE from the PACSES system. Recommendation: We recommend the County develop and adhere to controls to ensure correct information is being inputted and reported on these PACSES reports for accurate reporting. Management Response: The County will implement controls to sufficiently verify the accuracy of the information being input within PACSES in accordance with applicable criteria as outlined by OCSE.

View Audit 408135

Finding 1224639 (2023-008)

Material Weakness 2023

Serenity House of Clallam County

WA

Internal Control / Segregation of Duties Questioned Costs Allowable Costs / Cost Principles § 200.302 § 200.303

Reporting Recommendation: We recommend that the auditee implement procedures to ensure that Form 19-lA reimbursement requests are reviewed prior to submission to confirm that expenditures are charged to the correct approved budget line items. This may include maintaining a reconciliation between the...

Reporting Recommendation: We recommend that the auditee implement procedures to ensure that Form 19-lA reimbursement requests are reviewed prior to submission to confirm that expenditures are charged to the correct approved budget line items. This may include maintaining a reconciliation between the general ledger, the approved grant budget, and the Form 19-lA, as well as implementing supervisory review and approval of reimbursement submissions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. 2026 Action taken in response to finding: Reoccurring bills such as utilities, loan payments, contract services and credit card payments do not require an expense request to be included for on going bills. We will review our procedures and update our financial policy. 2023 Our financial process includes at least two reviews prior to creating a bill in our accounting system, payments are reviewed by the director or the Deputy Director when signed. We do not use a auto signature all checks are reviewed. 2023 The Grantor billing is a P&L detailed report for that grant and provides reconciliation monthly This is sorted into grant line items designated billable and non-billable for compliance. Total program cost and billable to grant are tracked every month, by the grant finance manager for compliance prior to billing any grants. Timecards are reviewed, expense requests are reviewed and payments are reviewed. Prior to submission of the invoice to grantor. 2023 Grant finance manager pulls copy of timecards, bills and checks to ensure compliance with reimbursements are accurate. Name(s) of the contact person(s) responsible for corrective action: Cora Alyea Planned completion date for corrective action plan: July 2023

View Audit 407897

Finding 1224635 (2023-004)

Material Weakness 2023

Serenity House of Clallam County

WA

Reporting § 200.303 § 200.508

SEFA Preparation Recommendation: We recommend that management design and implement effective internal controls over compliance related to SEFA preparation, including assigning responsibility to personnel with appropriate training in federal award requirements. Management should also implement a docu...

SEFA Preparation Recommendation: We recommend that management design and implement effective internal controls over compliance related to SEFA preparation, including assigning responsibility to personnel with appropriate training in federal award requirements. Management should also implement a documented review process, performed by a knowledgeable individual, to ensure the SEFA is complete, accurate, and compliant with Uniform Guidance prior to submission for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reached out to HUD Granter, Third Party Accounting Firm and in 2023. Followed up with a briefing from Auditor in 2025 for this audit. Name(s) of the contact person(s) responsible for corrective action: Sharon Maggard Planned completion date for corrective action plan: Completed

View Audit 407897

Finding 1224541 (2023-001)

Material Weakness 2023

New York State YMCA Foundation, Inc.

NY

Questioned Costs Reporting § 200.512

Management agrees with this finding and will review updated policies and procedures as adopted by bookkeepers. •Management will engage in consistent reviews and reconciliations to ensure that updated documentation is provided to auditors in a timely manner.•Executive Director Kyle Stewart will work ...

Management agrees with this finding and will review updated policies and procedures as adopted by bookkeepers. •Management will engage in consistent reviews and reconciliations to ensure that updated documentation is provided to auditors in a timely manner.•Executive Director Kyle Stewart will work in conjunction with the organization’s bookkeepers.•Action will be completed consistently and end of each fiscal year. Documentation and financial reports will be provided to auditors subsequent to execution of annual engagement. Annual audit requirements will be completed on time.

View Audit 407784

Finding 1224461 (2023-049)

Material Weakness 2023

Commonwealth of the Northern Mariana Islands

MP

Subrecipient Monitoring Procurement, Suspension & Debarment Reporting

Finding No.: 2023-049 AL Program: 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) COVID-19 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Area: Reporting Questioned Costs: $-0- Contact Person(s): Patrick Guerrero, Governor’s Authorized...

Finding No.: 2023-049 AL Program: 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) COVID-19 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Area: Reporting Questioned Costs: $-0- Contact Person(s): Patrick Guerrero, Governor’s Authorized Rep., PAO Corrective Action Plan: CNMI Public Assistance Office (PAO) agrees with the auditor's finding and conclusion. PAO acknowledges that required FFATA first-tier subaward reports were not submitted to the FFATA Subaward Reporting System (SAM.gov) for FEMA Public Assistance disasters DR-4235-MP, DR-4396-MP, DR-4404-MP, and DR-4511-MP during Fiscal Year 2023. The issue occurred because PAO did not have direct access to the FFATA reporting system and had not established formal written procedures to identify reportable subawards, track reporting deadlines, and ensure timely submission of required reports. In addition, monitoring controls over FFATA reporting requirements were not sufficiently developed to detect and prevent noncompliance. As a result, required reports were not submitted within the prescribed reporting period. The CNMI Public Assistance Office will implement the following corrective actions: • Develop and implement written FFATA reporting policies and procedures that establish responsibilities for identifying reportable subawards, preparing required reports, maintaining supporting documentation, obtaining supervisory review and approval, and documenting report submission. • Establish a centralized tracking log for all FEMA Public Assistance subawards to identify FFATA-reportable awards and monitor reporting deadlines. • Continue coordinating with the appropriate federal and CNMI agencies to obtain access to the FFATA Subaward Reporting System (SAM.gov) or identify an authorized entity responsible for submitting FFATA reports on behalf of the CNMI Public Assistance Office. • Conduct periodic management reviews of subaward activities and reporting requirements to ensure compliance with FFATA reporting deadlines and documentation requirements. PAO has made multiple requests for access to the FFATA reporting system and continues to follow up with the appropriate agencies regarding access and reporting responsibilities. Management has reviewed the audit finding and begun evaluating procedures needed to identify reportable Finding No.: 2023-049, continued AL Program: 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) COVID-19 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Area: Reporting Questioned Costs: $-0- Contact Person(s): Patrick Guerrero, Governor’s Authorized Rep., PAO Corrective Action Plan: subawards and track reporting requirements. PAO has initiated efforts to improve grant file organization and documentation management to support future compliance activities. Upon obtaining access to the appropriate reporting system or confirmation of the responsible reporting entity, PAO will review all current and future FEMA Public Assistance subawards for FFATA applicability and ensure required reports are submitted within established deadlines. The implementation of written procedures, supervisory review, and a subaward tracking system will provide ongoing monitoring and accountability to prevent future instances of noncompliance. The proposed completion date reflects the time necessary to obtain system access or establish reporting responsibilities, develop, and implement formal procedures, train responsible personnel, and fully integrate FFATA compliance monitoring into PAO's grant management processes. Proposed Completion Date: September 30, 2027

View Audit 407734

Finding 1224456 (2023-047)

Material Weakness 2023

Commonwealth of the Northern Mariana Islands

MP

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Finding No.: 2023-047 AL Program: 93.778 – Medical Assistance Program (Medicaid; Title XIX) Area: Special Tests and Provisions – Provider Eligibility (Screening and Enrollment) Questioned Costs: $28,448,121 Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: The Commonwealth...

Finding No.: 2023-047 AL Program: 93.778 – Medical Assistance Program (Medicaid; Title XIX) Area: Special Tests and Provisions – Provider Eligibility (Screening and Enrollment) Questioned Costs: $28,448,121 Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: The Commonwealth Medicaid Agency (CMA) respectfully disagrees with the auditor’s finding. CMA does not believe the finding fully reflects the Agency's efforts to comply with provider screening and exclusion requirements during the audit period. While documentation supporting certain screening activities was not readily available for auditor review, the Agency has historically performed provider eligibility and exclusion reviews as part of its enrollment and oversight processes. To further strengthen compliance and documentation practices, CMA has developed provider enrollment and screening procedures, conducted retrospective exclusion reviews where documentation was unavailable, and continues to enhance monitoring activities. In addition, the Agency has expanded staffing resources and continues to recruit and assign personnel dedicated Finding No.: 2023-047, continued AL Program: 93.778 – Medical Assistance Program (Medicaid; Title XIX) Area: Special Tests and Provisions – Provider Eligibility (Screening and Enrollment) Questioned Costs: $28,448,121 Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: to provider enrollment, compliance, and program integrity functions to ensure federal screening requirements are consistently performed, documented, and monitored. Proposed Completion Date: Ongoing

View Audit 407734

Finding 1224454 (2023-045)

Material Weakness 2023

Commonwealth of the Northern Mariana Islands

MP

Material Weakness Reporting Internal Control / Segregation of Duties

Finding No.: 2023-045 AL Program: 93.778 – Medical Assistance Program (Medicaid; Title XIX) Area: Reporting Questioned Costs: $-0- Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: The Commonwealth Medicaid Agency (CMA) respectfully disagrees with the auditor’s finding. Wh...

Finding No.: 2023-045 AL Program: 93.778 – Medical Assistance Program (Medicaid; Title XIX) Area: Reporting Questioned Costs: $-0- Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: The Commonwealth Medicaid Agency (CMA) respectfully disagrees with the auditor’s finding. While the Agency acknowledges that certain supporting documentation was not provided within the timeframe requested during the audit, CMA does not agree that the reported expenditures were unsupported. The Agency experienced resource and staffing constraints that affected its ability to compile and produce all requested documentation within the audit timeline. However, the office maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. To strengthen reporting processes and ensure timely availability of supporting records, CMA has developed reporting procedures and is currently recruiting a Fiscal Analyst position that will be responsible for CMS-64 reporting, reconciliations, documentation retention, and related federal reporting requirements. The Agency continues to improve its reporting processes and internal controls to ensure supporting documentation is maintained and readily available for future audits and reviews. Proposed Completion Date: Ongoing

View Audit 407734

Finding 1224452 (2023-043)

Material Weakness 2023

Commonwealth of the Northern Mariana Islands

MP

Reporting § 200.303

Finding No.: 2023-043 AL Program: 93.767 – Children’s Health Insurance Program (CHIP) Area: Reporting Questioned Costs: $-0- Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: The Commonwealth Medicaid Agency (CMA) respectfully disagrees with the auditor’s finding. While th...

Finding No.: 2023-043 AL Program: 93.767 – Children’s Health Insurance Program (CHIP) Area: Reporting Questioned Costs: $-0- Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: The Commonwealth Medicaid Agency (CMA) respectfully disagrees with the auditor’s finding. While the Agency acknowledges that certain supporting documentation was not provided within the timeframe requested during the audit, CMA does not agree that the reported expenditures were unsupported. The Agency experienced resource and staffing constraints that affected its ability to compile and produce all requested documentation within the audit timeline. However, the office maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. To strengthen reporting processes and ensure timely availability of supporting records, CMA has developed reporting procedures and is currently recruiting a Fiscal Analyst position that will be responsible for CMS-64 reporting, reconciliations, documentation retention, and related federal reporting requirements. The Agency continues to improve its reporting processes and internal controls to ensure supporting documentation is maintained and readily available for future audits and reviews. Proposed Completion Date: Ongoing

View Audit 407734

Finding 1224434 (2023-033)

Material Weakness 2023

Commonwealth of the Northern Mariana Islands

MP

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Finding No.: 2023-033 AL Program: COVID-19 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Reporting Questioned Costs: $-0- Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-3: The CNMI Department of Finance agrees with this finding. Requir...

Finding No.: 2023-033 AL Program: COVID-19 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Reporting Questioned Costs: $-0- Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-3: The CNMI Department of Finance agrees with this finding. Required Project and Expenditure Reports were not submitted for certain periods and supporting documentation and revenue loss calculations were unavailable for audit review. The primary cause was staff turnover and reorganization following a change in administration in FY 2023, which highlighted gaps in reporting capacity. This occurred alongside issues identified in the finding, including insufficient processes following CNMI’s transition from JD Edwards to Tyler Munis, missing supporting documentation, and lack of structured reporting controls. The proposed corrective actions are described below: a. Cross Training of Personnel (Implemented) CNMI DOF has cross trained multiple staff to ensure continuity and eliminate dependency on any single employee for revenue loss analysis and reporting and documentation retention. This improves data accuracy and prevents operational disruptions. b. Strengthening Data Extraction & Documentation Processes (In Progress) DOF is developing processes to reliably extract revenue related data from Tyler Munis to support timely revenue loss calculations, as recommended by auditors. Finding No.: 2023-033, continued AL Program: COVID-19 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Reporting Questioned Costs: $-0- Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: c. Municipal Training and Oversight Clarification (In Progress) CNMI will work closely with municipalities—particularly Rota, which is less familiar with federal grant requirements—to: • Clarify who is responsible for SLFRF reporting oversight • Verify the municipality’s elected option under the Final Rule • Provide training and technical assistance to ensure full compliance d. Development of reports DOF will formalize a written SOP establishing: • Required timelines • Documentation standards • Review procedures • Data retention requirements Proposed Completion Date: October 31, 2026 (Some actions already implemented; others underway)

View Audit 407734

Finding 1224430 (2023-029)

Material Weakness 2023

Commonwealth of the Northern Mariana Islands

MP

Reporting

Finding No.: 2023-029, continued AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Reporting Questioned Costs: $-0- Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: months after the closing of the fiscal year whereby the expenses s...

Finding No.: 2023-029, continued AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Reporting Questioned Costs: $-0- Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: months after the closing of the fiscal year whereby the expenses stabilized. As such, OGM should not be penalized for the difference in the SF425. OGM did provide the narrative report to EY for that reporting period. Furthermore, the Department of Finance had the responsibility in reporting of this program’s activities; OGM did not have access to the US Treasury portal. This further made it more difficult to catch-up with the reporting of items. Subsequently, US Treasury started requesting for different metrics or evidence to which our office was not prepared because we were operating under a set of understood deliverables, making it again difficult to report succinctly and accurately for the program. OGM was tasked by the former Governor last minute to handle this program because the state housing program did not want to manage this emergency rental assistance program due to the overload in workload brought on by the CDBG-Disaster program. Furthermore, OGM did provide EY with complete listing of expenses that matched the FMIS generated ending fund balance for this business unit. Regarding ERA1, US Treasury accepted the full report inclusive of SF425. For ERA2, a final report has been provided and is under full review. OGM will need to hire more financial analysts to meet the increased demand from programs such as CCERA-type programs. Furthermore, US Treasury has closed and accepted ERA1 reports. CCERA did return $1,746.41, inclusive of 5% interest to US Treasury under invoice # OCAERA0411A under the Collect Delinquent Indebtedness. Proposed Completion Date: Ongoing Condition 2a: The Office of Grants Management (OGM) disagrees with this finding. For ERA1 reports, US Treasury has accepted the final report and has closed all matters pertaining to this grant and this is substantiated by the return of funds amounting to $1,746.41. As noted, reports are very difficult to generate without full access to real-time data and the lack of software. The immense load and pressure to execute welfare assistance can be very overwhelming. I ask that this finding be removed as all reports have been accepted by US Treasury for ERA 1. Proposed Completion Date: Ongoing Finding No.: 2023-029, continued AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Reporting Questioned Costs: $-0- Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: Condition 2b: The Office of Grants Management (OGM) disagrees with this finding. For ERA 2, reports are very difficult to generate without full access to real-time data and the lack of software. The immense load and pressure to execute welfare assistance can be very overwhelming. OGM will need to hire more financial analysts in the future to meet the increased demand from programs such as CCERA-type programs. Additional monitoring controls and systematic filing will need to exist in the future related work to improve reporting requirements. Proposed Completion Date: Ongoing Condition 2c: The Office of Grants Management (OGM) disagrees with this finding. We believe this condition is substantially related to the reporting concerns identified under Condition 2b and reflects the same underlying reporting and documentation challenges. Because the supporting accounting records and narrative reporting requirements are interconnected, the Office respectfully requests consideration of consolidating this condition with Condition 2b to avoid duplication of findings addressing the same underlying issue. Proposed Completion Date: Ongoing

View Audit 407734

Finding 1224428 (2023-027)

Material Weakness 2023

Commonwealth of the Northern Mariana Islands

MP

Allowable Costs / Cost Principles Reporting

Finding No.: 2023-027 AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Allowable Costs/Cost Principles Questioned Costs: $53,435 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: Condition 1a: The Office of Grants Management (OGM) ...

Finding No.: 2023-027 AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Allowable Costs/Cost Principles Questioned Costs: $53,435 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: Condition 1a: The Office of Grants Management (OGM) respectfully disagrees with this finding. Under the U.S. Department of the Treasury's Emergency Rental Assistance Program 2 (ERA2), states, territories, and other eligible grantees were expressly authorized to pay rental arrears (past-due rent) on behalf of eligible households. Treasury guidance states that ERA2 financial assistance could include current rent, rental arrears (back rent), utility and home energy costs, utility and home energy arrears, and other housing-related expenses. Finding No.: 2023-027, continued AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Allowable Costs/Cost Principles Questioned Costs: $53,435 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: Treasury's FAQ further clarifies that: A grantee may provide assistance for rental arrears that accrued on or after March 13, 2020. A grantee was not required to pay the full amount of arrears and could structure the program to provide partial assistance if desired. For the CNMI specifically, if your ERA2 award was active during the period of performance, payment of eligible rental arrears was an allowable use of funds. However, Treasury closed the ERA2 program on September 30, 2025, and ERA2 funds may no longer be used to provide new rental assistance, including rental arrears. As a practical matter, many ERA programs adopted policies of paying up to three months of future rent at a time, but that was often a program design choice or carried over from ERA1 administration rather than a statutory ERA2 limitation. The controlling Treasury guidance limits total assistance to 18 months combined across ERA1 and ERA2. The CNMI followed US Treasury Guidelines and pushed for a combined 18-month max limit, if financially needed, across ERA1 and ERA2. Therefore, the Office disagrees with the $30,336 questioned cost and we are requesting that this finding be removed based on our explanation above. Proposed Completion Date: Ongoing Condition 1b: The Office of Grants Management (OGM) respectfully disagrees with this finding. Under the U.S. Department of the Treasury's Emergency Rental Assistance Program 2 (ERA2), states, territories, and other eligible grantees were expressly authorized to pay rental arrears (past-due rent) on behalf of eligible households. Treasury guidance states that ERA2 financial assistance could include current rent, rental arrears (back rent), utility and home energy costs, utility and home energy arrears, and other housing-related expenses. Treasury's FAQ further clarifies that: A grantee may provide assistance for rental arrears that accrued on or after March 13, 2020. A grantee was not required to pay the full amount of arrears and could structure the program to provide partial assistance if desired. For the CNMI specifically, if your ERA2 award was active during the period of performance, payment of eligible rental arrears was an allowable use of funds. However, Treasury closed the Finding No.: 2023-027, continued AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Allowable Costs/Cost Principles Questioned Costs: $53,435 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: ERA2 program on September 30, 2025, and ERA2 funds may no longer be used to provide new rental assistance, including rental arrears. As a practical matter, many ERA programs adopted policies of paying up to three months of future rent at a time, but that was often a program design choice or carried over from ERA1 administration rather than a statutory ERA2 limitation. The controlling Treasury guidance limits total assistance to 18 months combined across ERA1 and ERA2. Therefore, the Office disagrees with the $5,452 questioned cost and we are requesting that this finding be removed based on our explanation above. Proposed Completion Date: Ongoing Condition 1c: The Office of Grants Management (OGM) respectfully disagrees with the findings because using the Purchase Requisition or Purchase Order methodology is not the only method of obtaining goods or services in the CNMI Government. In this situation, the Office opted to use the Invoice Central method in MUNIS. Items for purchase were specifically identified in the portal and it was approved by the Division of Financial Services. The items being purchased are allowable items (office supplies); however, the method used by the Office may not be acceptable by the auditor. Again, the Office disagrees as DOF officials approved the transaction and paid the item out with check#619104. The invoice # for this transaction is 739384-0. If the transaction is not allowable, then DOF should update their SOPs or not allow the Invoice Entry module to be used. Again, we disagree with the finding and questioned cost amounting to $3,485.39. Therefore, the Office disagrees with the $3,485.39 questioned cost and we are requesting that this finding be removed based on our explanation above. Proposed Completion Date: Ongoing Finding No.: 2023-027, continued AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Allowable Costs/Cost Principles Questioned Costs: $53,435 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: Condition 2a: The Office of Grants Management (OGM) respectfully disagrees with this finding. After the audit inquiry, the supporting timesheet associated with the questioned payroll costs was located and is available for review. The documentation substantiates the payroll charges previously questioned. Accordingly, the Office respectfully disagrees with the questioned costs of $1,159 and requests removal of this finding. Proposed Completion Date: Ongoing Condition 2b: The Office of Grants Management (OGM) respectfully disagrees with this finding. The payroll costs in question are traceable within the financial management system; however, the reporting format aggregates payroll and fringe benefit expenditures in a manner that may make individual employee costs difficult to identify without familiarity with the system's reporting structure. The questioned amount of $658.17 can be reconciled to supporting payroll records and underlying accounting data. The Office is prepared to provide additional supporting documentation and reconciliation schedules to demonstrate the traceability of these costs. Accordingly, the Office respectfully disagrees with the questioned costs of $658 and requests removal of this finding. Proposed Completion Date: Ongoing Condition 3: The Office of Grants Management (OGM) respectfully disagrees with the findings and questioned costs of $12,345.00. According to our records and using budgetary print template reports, the following has been spent: Finding No.: 2023-027, continued AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Allowable Costs/Cost Principles Questioned Costs: $53,435 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: The CCERA Program spent in total $10,398,930.38 out of the total award of $10,400,669.30, leaving an unspent balance of $1,738.92. This is also reported in the final submitted report to US Treasury. US Treasury accepted the report and advised us to return the unused funds plus 5% interest, which changed the total owed to $1,746.41. This is substantiated by a notice from US Treasury to Collect for Delinquent Indebtedness under Invoice# OCAERA0411A dated March 11, 2025. Thus, confirming that the CNMI only spent $10,398,930.38 under ERA1. Furthermore, there are internal controls built into the MUNIS System that will not allow us to exceed the budgeted amount, so we are not able to exceed the budgeted amount. Thus, the Office disagrees with the $12,345 questioned cost and we are requesting that this finding be removed based on our explanation above. Proposed Completion Date: Ongoing

View Audit 407734

Finding 1224397 (2023-014)

Material Weakness 2023

Commonwealth of the Northern Mariana Islands

MP

Subrecipient Monitoring Reporting § 200.303 § 200.330

Finding No.: 2023-014 AL Programs: 11.307 – Economic Adjustment Assistance Area: Reporting Questioned Costs: $-0- Contact Person(s): Elizabeth S. Balajadia, Office of Planning and Development Acting Director / James Kintol, Project Manager, Department of Finance Corrective Action Plan: Condition 1: ...

Finding No.: 2023-014 AL Programs: 11.307 – Economic Adjustment Assistance Area: Reporting Questioned Costs: $-0- Contact Person(s): Elizabeth S. Balajadia, Office of Planning and Development Acting Director / James Kintol, Project Manager, Department of Finance Corrective Action Plan: Condition 1: For project no. FG17010001 (related to the Economic Resiliency Center), the CNMI Department of Finance respectfully disagrees with this finding. The Department was not aware that a documentation request had been submitted through the EY portal. This occurred because the ERC project was grouped with other OPD-related projects within the same EY portal request, resulting in the Department not receiving clear notification that additional documents were required. The Department maintains all relevant supporting documentation for these transactions and such documentation is available for review upon request from the Grantor. The Office of Planning and Development partially disagrees with the finding related to Project No. FG26050001 and FG26050006. OPD has located the SF-425 Federal Financial Report for Project No. FG26050001 / Grant Award No. 07-79-07631 for the reporting period ending September 30, 2022, and the report is maintained by OPD and available for review. With respect to Project No. FG26050006 / Grant Award No. ED22SEA3070013, OPD has been unable to locate the referenced SF-425 reports for the reporting periods ending September 30, 2022, and March 31, 2023. However, although the grant was awarded in 2022, the project was not established until June 12, 2023, and grant activities had not commenced during the reporting periods cited in the finding. OPD will coordinate with the Department of Finance to determine whether reporting requirements applied during the referenced periods. Should additional guidance or clarification indicate that such reporting requirements were applicable, OPD will review the information provided and take appropriate action, as necessary. Correspondence from the Department of Finance confirming the project establishment date is available for review. OPD will continue coordinating with the Department of Finance and reviewing grant award documentation to determine whether reporting requirements applied during the referenced reporting periods and to identify any records relevant to the audit finding. No further corrective action is proposed at this time pending clarification of the applicable reporting requirements. Proposed Completion Date: Ongoing Condition 2a: For project no. FG17010001 (related to the Economic Resiliency Center), the Department of Finance respectfully disagrees with this finding. The Department was not aware that a documentation request had been submitted through the EY portal. This occurred because the ERC Finding No.: 2023-014, continued AL Programs: 11.307 – Economic Adjustment Assistance Area: Reporting Questioned Costs: $-0- Contact Person(s): Elizabeth S. Balajadia, Office of Planning and Development Acting Director / James Kintol, Project Manager, Department of Finance Corrective Action Plan: project was grouped with other OPD-related projects within the same EY portal request, resulting in the Department not receiving clear notification that additional documents were required. The Department maintains all relevant supporting documentation for these transactions and such documentation is available for review upon request from the Grantor. The Office of Planning and Development (OPD) respectfully disagrees with the finding related to Project No. 2605210018. OPD has located the SF-271 Outlay Reports and Requests for Reimbursement for Construction Program for Project No. 2605210018 / Grant Award No. 07-79-07562 covering the periods July 1, 2022, through October 31, 2022, and November 1, 2022, through January 9, 2023. These records are maintained by OPD and are available for review. No further corrective action is proposed. OPD has located the requested SF-271 reports and confirmed that they are maintained within its grant records and available for review. OPD will continue maintaining grant records in accordance with applicable record-retention requirements. Proposed Completion Date: Ongoing Condition 2b: The Office of Planning and Development (OPD) respectfully disagrees with the finding. OPD has located supporting accounting records associated with the SF-271 for Project No. 2605210018 / Grant Award No. 07-79-07562 covering the period August 29, 2022, through April 30, 2023, including invoices, purchase orders, and check copies. These records are maintained by OPD and are available for review. No further corrective action is proposed. The requested supporting records have been located and are maintained by OPD for review. OPD will continue maintaining supporting financial documentation in accordance with applicable record-retention requirements. Proposed Completion Date: Ongoing Condition 3a: For project no. FG17010001 (related to the Economic Resiliency Center), the Department of Finance respectfully disagrees with this finding. The Department was not aware that a documentation request had been submitted through the EY portal. This occurred because the ERC project was grouped with other OPD-related projects within the same EY portal request, resulting in the Department not receiving clear notification that additional documents were required. The Department maintains all relevant supporting documentation for these transactions and such documentation is available for review upon request from the Grantor. Finding No.: 2023-014, continued AL Programs: 11.307 – Economic Adjustment Assistance Area: Reporting Questioned Costs: $-0- Contact Person(s): Elizabeth S. Balajadia, Office of Planning and Development Acting Director / James Kintol, Project Manager, Department of Finance Corrective Action Plan: The Office of Planning and Development (OPD) respectfully disagrees with the finding. OPD has located the performance reports for Project No. FG26050001 / Grant Award No. 07-79-07631 and Project No. 2605210018 / Grant Award No. 07-79-07562 for the reporting period ending September 30, 2022. OPD believes the reports referenced in the finding as Periodic Performance Reports are maintained and submitted by OPD as Quarterly Progress Reports (QPRs). These records are maintained by OPD and are available for review. No further corrective action is proposed. The requested performance reports have been located and are maintained by OPD for review. OPD will continue maintaining programmatic records in accordance with applicable record-retention requirements. Proposed Completion Date: Ongoing Condition 3b: The Office of Planning and Development (OPD) agrees with the finding. The Periodic Performance Report for Project No. 2605210018 / Grant Award No. 07-79-07562 for the reporting period ending December 31, 2022, was submitted after the required due date. Although operational circumstances at the time contributed to the delay, OPD recognizes the importance of timely reporting and will strengthen internal monitoring procedures to improve tracking of reporting deadlines and support timely submission of all required reports. OPD will implement a reporting calendar and periodic internal reviews to monitor upcoming reporting deadlines and ensure timely submission of all required reports. Proposed Completion Date: Ongoing Condition 4: For project no. FG17010001 (related to the Economic Resiliency Center), the CNMI Department of Finance respectfully disagrees with this finding. Based on the project’s Special Award Conditions, the only reporting requirements identified for this award are the submission of Project Progress Reports and Financial Reports (SF-425). No additional reporting or documentation requirements – beyond those explicitly stated – were communicated to the Department. Accordingly, the Department requests further clarification from the auditor regarding the specific authority or requirement that forms this basis of this finding, including where such a requirement Finding No.: 2023-014, continued AL Programs: 11.307 – Economic Adjustment Assistance Area: Reporting Questioned Costs: $-0- Contact Person(s): Elizabeth S. Balajadia, Office of Planning and Development Acting Director / James Kintol, Project Manager, Department of Finance Corrective Action Plan: is documented. A copy of the Special Award Conditions is maintained by the Department and is available for review upon request. The Office of Planning and Development (OPD) respectfully disagrees with the finding. OPD reviewed the grant files, including the applicable Special Award Conditions, for Project No. 2605210018 / Grant Award No. 07-79-07562 and Project No. FG26050001 / Grant Award No. 07- 79-07631. OPD was unable to identify a requirement for submission of an Annual Performance Technical Report within the grant terms and conditions governing these awards. The applicable Special Award Conditions have been identified and are available for review. OPD respectfully requests clarification regarding the specific report referenced in the finding and will provide any applicable documentation should an applicable reporting requirement be identified. OPD will review any additional guidance or clarification provided regarding the reporting requirements applicable to these grants and will take appropriate action, if necessary. OPD will continue reviewing grant award requirements and maintaining documentation of applicable reporting obligations to support compliance and future audit reviews.

View Audit 407734

Finding 1224395 (2023-012)

Material Weakness 2023

Commonwealth of the Northern Mariana Islands

MP

Reporting

Finding No.: 2023-012 AL Programs: COVID-19 10.542 – Pandemic EBT Food Benefits (P-EBT) Area: Reporting Questioned Costs: $-0- Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: The CNMI NAP agrees with the auditor’s finding and conclusions. The issue occurred because of co...

Finding No.: 2023-012 AL Programs: COVID-19 10.542 – Pandemic EBT Food Benefits (P-EBT) Area: Reporting Questioned Costs: $-0- Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: The CNMI NAP agrees with the auditor’s finding and conclusions. The issue occurred because of competing priorities in our partner agencies and delays in the overall process for preparing and submitting the quarterly Federal Financial Reports (SF-425). This has been a recurring finding in prior years, including the FY23 Financial Management Review. To prevent recurrence, the CNMI NAP will perform the following: • Establish a formal internal checklist and timeline for NAP’s portion of the SF-425 preparation process. • Implement a centralized electronic filing system for all reporting supporting documentation. • Assign a designated NAP staff member to track submission status and perform a final quality review prior to each quarterly submission. Finding No.: 2023-012 AL Programs: COVID-19 10.542 – Pandemic EBT Food Benefits (P-EBT) Area: Reporting Questioned Costs: $-0- Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: • Schedule regular coordination meetings with all involved departments to improve data-sharing timelines and accountability. • Conduct annual training for relevant NAP fiscal staff on federal reporting requirements and internal escalation procedures. Proposed Completion Date: September 30, 2026

View Audit 407734

Finding 1224310 (2023-004)

Material Weakness 2023

Santo Domingo Tribal Housing Authority

NM

Reporting

Management’s Response: The SDTHA management concurs that a problem exists with the financial reporting for the IHBG award. During the 2019 HUD monitoring, it was noted that there were issues with expenditures and what was allowable expenses. SDTHA management has been working diligently to correct an...

Management’s Response: The SDTHA management concurs that a problem exists with the financial reporting for the IHBG award. During the 2019 HUD monitoring, it was noted that there were issues with expenditures and what was allowable expenses. SDTHA management has been working diligently to correct and ensure all expenditures are all allowable. SDTHA management will complete all 425’s once the audits have been completed. Timeline and Estimated Completion Date: December 31, 2026 Responsible Official: Jonah Garcia, Finance Officer

View Audit 407599

Finding 1224308 (2023-003)

Material Weakness 2023

Santo Domingo Tribal Housing Authority

NM

Reporting Internal Control / Segregation of Duties

Management’s Response: SDTHA’s management concurs that a problem exists with financial reporting for the IHBG award. During the HUD monitoring for 2019 and the subsequent audits, issueswere noted with expenditures. These issues were brought up to management in 2020, which resulted in having to compl...

Management’s Response: SDTHA’s management concurs that a problem exists with financial reporting for the IHBG award. During the HUD monitoring for 2019 and the subsequent audits, issueswere noted with expenditures. These issues were brought up to management in 2020, which resulted in having to complete the 2018 audit. The audit reports are cumulative, ending balances from the prior year are carried over to the beginning of the next year, so this has slowed down the completion of timely filing. SDTHA developed a plan to have 2023 completed by quarter two of 2026, 2024 and 2025 audits to be completed before the end of 2026 Timeline and Estimated Completion Date: December 31, 2026 Responsible Official: Lorrie Chavez, Executive Director and Jonah Garcia, Finance Officer

View Audit 407599

Finding 1224302 (2023-002)

Material Weakness 2023

Prevent Child Abuse Utah

UT

Questioned Costs Subrecipient Monitoring Material Weakness § 200.512

Management should establish and implement a robust tracking system to monitor reporting deadlines, ensure timely financial statement preparation, and improve coordination with external auditors. Additionally, assigning a compliance officer or designated staff member responsible for tracking audit pr...

Management should establish and implement a robust tracking system to monitor reporting deadlines, ensure timely financial statement preparation, and improve coordination with external auditors. Additionally, assigning a compliance officer or designated staff member responsible for tracking audit progress and submission deadlines can help prevent future delays.

View Audit 407583

Finding 1224235 (2023-013)

Material Weakness 2023

International Fertilizer Development Company

AL

Questioned Costs Reporting Significant Deficiency § 200.512

2023-013-Late filing of the data collection form Suggested Action: Enhanced internal controls and timelines around the year-end close and audit coordination to ensure timely completion of future audits and related filings. Responsible Official: Global Finance Director Completion Date: 6/30/2026

View Audit 407579

Finding 1224222 (2023-012)

Material Weakness 2023

International Fertilizer Development Company

AL

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.302 § 200.331 § 200.332

2023-012-Subrecipient Monitoring Suggested Action: Enhanced contractual requirements that ensure greater subrecipient monitoring around greater support for any requests or assertions from our subrecipients. Responsible Official: Chief Operations Officer Completion Date: 6/30/2026

View Audit 407579

Finding 1224183 (2023-009)

Material Weakness 2023

International Fertilizer Development Company

AL

Reporting Material Weakness § 200.508

2023-009-Reconciliation of accounts Suggested Action: Ensure proper month end close, including reconciliation of major accounts. Responsible Official: Assistant Controller Completion Date: 4/30/2026

View Audit 407579

Finding 1224019 (2023-004)

Material Weakness 2023

LAND MANOR, INC.

TX

Reporting Internal Control / Segregation of Duties

Control Activities Corrective Action Plan: The Corrective Action Plan referenced at 2023-002/003 will be expanded to include internal control over program compliance. The Monitoring Program being considered at 2023-001 would enhance compliance awareness on the part of program employees. Anticipated ...

Control Activities Corrective Action Plan: The Corrective Action Plan referenced at 2023-002/003 will be expanded to include internal control over program compliance. The Monitoring Program being considered at 2023-001 would enhance compliance awareness on the part of program employees. Anticipated Completion Date: July 15, 2026 Responsible Party: Land Manor Executive Director, Quality Management Coordinator and Program Directors.

View Audit 407429

Finding 1223936 (2023-003)

Material Weakness 2023

Hope Toledo Services

OH

Questioned Costs HUD Housing Programs Reporting

Reporting Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that reports are prepared and reviewed by separate individuals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/tak...

Reporting Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that reports are prepared and reviewed by separate individuals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will put a formal layer of review after preparation of the report and before submission to the grantor. Name of the contact person responsible for corrective action: John C. Jones, President and CEO Planned completion date for corrective action plan: 9/30/2026

View Audit 407341

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